- 36 - include in that "Income per return" figure the $49,525 of 1988 White Star compensation that petitioners reported on line four of their 1988 Schedule C as "Other income". Consequently, respon- dent determined that for 1988 petitioners had $228,119 of unre- ported gross receipts of Design Consultants. Respondent also determined in the notice that petitioners are entitled to certain deductions for 1987 and 1988 that they did not claim in their returns for those years and that petition- ers are not entitled to certain of the cost of goods sold and deductions that they claimed in their 1986, 1987, and 1988 returns totaling $102,980, $102,705, and $146,641, respectively. With respect to respondent's determinations disallowing, inter alia, certain of the cost of goods sold and deductions that petitioners claimed, respondent's representatives obtained from petitioners and reviewed oral and/or written information regard- ing at least certain of those items about which respondent had questions. Petitioners' Criminal Trial and Conviction On April 14, 1993, a grand jury indicted petitioners on three counts of violating section 7201 by willfully attempting to evade and defeat a large part of the income tax due and owing by them to the United States for 1986, 1987, and 1988. Petitioners were tried in the U.S. District Court for the District of New Hampshire (District Court) on January 24, 1994, and a jury found petitioners guilty of violating section 7201 for 1987 and acquit-Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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